Asset-Referenced Token (ART)

An asset-referenced token is one of MiCA's two stable-value classes. Article 3(1)(6) defines it as a crypto-asset "that is not an electronic money token and that purports to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies." Redemption is at the market value of what the token references, not at par, and the issuer needs authorisation from a national competent authority before any public offer.

The definition is written as a residual. A stable-value token that is not an e-money token is an ART, so the class is decided by failing the single-currency test rather than by matching a positive description, and referencing two official currencies is enough to land here.

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The redemption promise is the tell. Par redemption means EMT, market-value redemption means ART, and MiCA makes the two mutually exclusive by defining an ART as a token that is not an EMT.

The definition turns on one word

MiCA writes the two stable-value classes as a pair, and the pair is exclusive. An e-money token references "the value of one official currency." An asset-referenced token is a crypto-asset that is not an e-money token and references "another value or right or a combination thereof, including one or more official currencies."¹ The word doing the work is "another." Anything other than a single official currency, and any combination, lands in the ART class.

That catches designs teams do not expect. A token referencing euro and US dollar together is an ART, not two EMTs and not a lighter product, because it references more than one currency. A token referencing gold is an ART. A token referencing a basket of crypto-assets is an ART. The three European supervisory authorities put the same point in consumer language: ARTs reference "another value or right or a combination thereof (e.g. official currency, commodities, other assets)," and "you can redeem ART at the market value of the asset(s) it references."² The commercial cost of that line is real: a different issuer eligibility test, a different reserve floor and a different capital plan from the one an e-money token needs.

Authorisation, and the 25 working day clock

Only credit institutions and MiCA-authorised issuers may offer an ART to the public or seek its admission to trading in the EU.² Authorisation comes from the national competent authority in the issuer's home member state, and Article 21(1) requires that authority to take "a fully reasoned decision granting or refusing authorisation" within 25 working days of receiving the opinions referred to in Article 20(5).¹

One detail is worth planning around. Where authorisation is granted, the issuer's crypto-asset white paper "shall be deemed to be approved" with it.¹ The white paper is not a separate filing you clear afterwards. It is part of the application, so the disclosure document and the authorisation case are drafted together or not at all.

The reserve is ring-fenced by statute

Article 36 requires issuers to "constitute and at all times maintain a reserve of assets," legally segregated from the issuer's own estate and from the reserves of other asset-referenced tokens, "so that creditors of the issuers have no recourse to the reserve of assets, in particular in the event of insolvency."¹ This is bankruptcy remoteness written into the regulation rather than argued for in a structure memo.

Composition is constrained too. Article 36(4) directs the EBA to set minimum amounts held as deposits in credit institutions, and those minimums "cannot be lower than 30% of the amount referenced in each official currency." For a token designated significant, Article 45 raises that floor to 60% and lifts own funds to 3% of average reserve assets.¹ A reserve strategy built on yield rather than on deposits does not survive the technical standards.

Redemption at market value, with no fee and no interest

Article 39 gives holders "a right of redemption at all times against the issuers." On request, the issuer redeems either by paying an amount in funds equivalent to the market value of the referenced assets, or by delivering those assets, and "the redemption of asset-referenced tokens shall not be subject to a fee."¹ Market value, not par: an ART holder carries the price risk of the basket, which is precisely why the class exists separately from e-money tokens.

Article 40(1) then closes the yield route: "Issuers of asset-referenced tokens shall not grant interest in relation to asset-referenced tokens."¹ Whatever the reserve earns stays with the issuer. Any revenue model has to come from issuance and redemption spreads, distribution, or services around the token, because the one obvious lever for attracting float is unavailable by law.

Significant status changes the book

Designation as significant is not a badge. Article 45 adds a remuneration policy, portability of custody across service providers, liquidity stress testing, the higher own-funds percentage and the higher deposit floor, and supervision moves to the European Banking Authority for significant issuers.¹ The EBA published a decision on the procedure for that significance assessment on 22 October 2024, covering assessment timelines, reporting and supervisory transfer rules.³

Two more documents are required of every ART issuer regardless of size. Article 46 requires a recovery plan, notified within six months of authorisation, setting out options including liquidity fees on redemptions, redemption limits and suspension of redemptions. Article 47 requires a separate orderly redemption plan for insolvency or withdrawal of authorisation.¹ Growth into significance should therefore be modelled as a step change in cost, planned before the threshold is near rather than after a supervisor raises it.

What this means at design time

Three decisions follow directly. What the token references, because a second currency or a commodity moves you out of the EMT regime and into this one with a different issuer eligibility test. Where the entity sits, since that fixes the national competent authority reading your application and your white paper. And whether the model works with reserve income retained by the issuer, at least 30% of each currency leg in bank deposits, and free redemption at market value on demand.

MiCA also sits on unsettled practice rather than long precedent. The EBA was still corresponding with the Commission about amendments to the ART authorisation technical standards in February 2025, after the regulation's full application date, so supervisory expectations are still forming.³ Whether a specific token is an ART, an EMT or something outside MiCA entirely is fact-specific and member-state-specific, and the call belongs to your counsel and the relevant authority. This page is reference material for design work. It is not legal advice, and it is not a recommendation to buy, sell or hold any asset.

Common questions

What is the difference between an asset-referenced token and an e-money token?

The reference value and the redemption promise. An e-money token references one official currency and is redeemed at par value. An asset-referenced token is defined as a token that is not an e-money token and references another value or right, or a combination including more than one official currency, and is redeemed at the market value of what it references.¹ Issuer eligibility differs as well.

Is a gold-backed token an asset-referenced token under MiCA?

A token that purports to maintain a stable value by referencing gold falls within the ART definition, because gold is not an official currency and the class covers "another value or right."¹ The joint ESAs factsheet lists commodities among the reference assets for ARTs.² Whether a specific gold token is instead a financial instrument, and so outside MiCA, is a separate question for counsel.

Can an asset-referenced token pay interest to holders?

No. Article 40(1) states that issuers of asset-referenced tokens shall not grant interest in relation to those tokens.¹ Reserve income accrues to the issuer instead. The same prohibition applies to e-money tokens under Article 50(1), so neither MiCA stable-value class can compete for holders by sharing reserve yield, and revenue has to come from elsewhere.

Who authorises an asset-referenced token issuer?

The national competent authority in the issuer's home member state, which must issue a fully reasoned decision within 25 working days of receiving the opinions referred to in Article 20(5).¹ Only credit institutions and MiCA-authorised issuers may offer ARTs publicly in the EU.² Issuers of tokens designated as significant move to direct supervision by the European Banking Authority.

See MiCA Compliance and Tokenomics for how this applies in practice.

Sources

Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), consolidated text
EUR-Lex, Official Journal of the European Union, 2023
Primary text. Articles 3(1)(6) definition, 21 authorisation, 36 reserve, 39 redemption, 40 interest ban, 45 significant issuers, 46 and 47 recovery and redemption plans.
Crypto-assets explained: What MiCA means for you as a consumer
Joint ESAs (EBA, EIOPA, ESMA), Publications Office of the European Union, 2025
Regulator-issued plain-language description of ART reference assets, redemption at market value and issuer eligibility.
Asset-referenced and e-money tokens (MiCA), document index
European Banking Authority
Dated record of the EBA's ART and EMT workstream, including the 22 October 2024 decision on the significance assessment procedure and the February 2025 letter to the Commission on RTS amendments.

Last reviewed 2026-08

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